State of Michigan AFFIDAVIT Case No: 2022-0338639.

54B District Court IN SUPPORT OF COMPLAINT District:

East Lansing Circuit:
People v. Lee Chatfield

THE COMPLAINING WITNESS, ON INFORMATION AND BELIEF, SAYS:

1. Affiant, Special Agent Robert Menard, is a Special Agent with the Michigan
Department of Attorney General's Criminal Investigations Division and has been
employed as a law enforcement officer for thirty-three years. Affiant is currently
assigned to the Major Case Section of the Criminal Division. Affiant has
successfully completed the Wayne County Regional Police Academy and has
received specialized training in violent crimes, homicide, robbery, arson
investigation, fugitive apprehensions, financial crimes, narcotics investigations, and
drug trafficking organization conspiracy investigations. Furthermore, Affiant has
over 20 years of specialized investigative experience and has been involved in
multiple complex criminal investigations.

2. Affiant states that in January of 2022, he was assigned to investigate allegations

made by Rebekah Chatfield, the sister-in-law of former Speaker of the Michigan
House of Representatives Lee Chatfield, for misappropriation of non-profit and
political action committee money tied to Lee Chatfield when he was an elected
public official in Michigan. Other special agents of the Michigan Department of
Attorney General and detectives with the Michigan State Police were also assigned.
Rebekah alleged, among other things, that Lee Chatfield misappropriated money
that he raised for political and non-profit purposes and used the money for illegal
purposes. During the investigation, it became clear that Robert and Anne Minard,
senior staffers for Lee Chatfield, were intimately involved in misappropriation of
these funds and others. Robert and Anne Minard each have criminal cases
scheduled for preliminary examination in this Court.

3. In 2011, Robert and Anne Minard founded a political consulting firm, Victor
Strategies. The firm specialized in campaign consulting and fund-raising. In 2013,
Robert Minard was introduced to Lee Chatfield as someone who may run for
political office in the future. At the time, Robert was employed as a political
consultant at his firm Victor Strategies and saw Chatfield as a potential client. Two
months after their initial meeting, Robert assisted with Chatfield's campaign for
State Representative in the Michigan House of Representatives. Chatfield won the
election. Robert and Anne Minard began working for Chatfield in his first term as a
St!l]te Representative from January 2015 through December 2017.
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4. t;,~)l;(atfield was elected for a second term, from January 2017 through December
~2dis, and held the position of Speaker Pro Tem. This is the number two leadership
?~g*tion in the Michigan House of Representatives. In Chatfield's final term, from
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 January 2019 through December 2020, he held the position of Michigan Speaker of
the House. This is the most powerful position in the Michigan House of
Representatives. Robert and Anne Minard continued to be employed in the
Michigan House of Representatives throughout Chatfield's tenure in office which
culminated in Robert serving as Chatfield's Chief of Staff during the time Chatfield
was Speaker. Anne Minard served as Chatfield's Director of External Affairs during
the time Chatfield was Speaker.

5. Lee Chatfield is manied to Stephanie Chatfield. Lee Chatfield has several siblings
including Paul Chatfield and Aaron Chatfield. Aaron is manied to Rebekah
Chatfield.

6. Aaron Chatfield worked for the Michigan House of Representatives. When Lee
Chatfield became Speaker of the House, he began working for Grand River
Strategies. Aaron Chatfield worked for Grand River Strategies through 2019. Even
though he was not Lee Chatfield's employee, Aaron Chatfield had a working
relationship with Lee Chatfield, where he often served as Lee Chatfield's driver and
ran various errands for Lee Chatfield.

7. Paul Chatfield worked for the Michigan House of Representatives in caucus services
from 2017-2018. From approximately January of 2020 through July of 2020 Paul
worked for the Republican Party doing campaign work.

8. Robert Anderson worked for the House of Representatives in Caucus Services. In

2017 he was hired by Lee Chatfield and Robert Minard to work as his as Lee
Chatfield's Constituent Relations Director. Robert Anderson worked in this capacity
through 2020.

9. Wilbur Lovitt was a childhood friend of Aaron and Paul Chatfield. He was not one
of Lee Chatfield's office employees at the Michigan House of Representatives.

IO.Aaron, Paul, and Wilbur helped with Lee's first campaign in 2014. During Lee
Chatfield's tenure at the Michigan House of Representatives, Robert Minard, Aaron
Chatfield, Paul Chatfield, Robert Anderson, and Wilbur Lovitt frequently
accompanied Lee Chatfield during Lee's personal and business-related travel.

11. Throughout this tenure, Robert and Anne Minard maintained operation and
ownership of Victor Strategies which contracted with Chatfield's candidate
committee, Chatfield's Independent Political Action Committees (PA Cs), 501(C)(4)
non-profits associated with Chatfield and the Michigan House Republican
Campaign Committee (HRCC), as well as separate independent PA Cs and
candidate committees not associated with Chatfield, among other clients.
Additionally, Robert and Anne Minard maintained and operated their own
501(C)(4) non-profit organization named Lift Up Michigan.

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 12. The Michigan Campaign Finance Act defines, in part, the entities described above
in the following ways:

• Committee: A person that receives contributions or makes expenditures for

the purposes of influencing or attempting to influence the action of the voters
for or against the nomination or election of a candidate, the qualification,
passage, or defeat of a ballot question, or the qualification of a new political
party, if contributions received total $500.00 or more in a calendar year or
expenditures made total $500.00 or more in a calendar year. MCL 169.203(4)
• Candidate committee: A committee designated in a candidate's filed
statement of organization as that individual's candidate committee. A
candidate committee must be under the control and direction of the candidate
named in the same statement of organization. MCL 169.203(2)
• Independent committee 1: A committee, other than a political party
committee, that before contributing to a candidate committee ofa candidate
for elective office under section 52(2) or 69(2) files a statement of organization
as an independent committee at least 6 months before an election for which it
expects to accept contributions or make expenditures in support of or in
opposition to a candidate for nomination to or election to an elective office;
and receives contributions from at least 25 persons and makes expenditures
not to exceed the limitations of section 52(1) in support of or in opposition to 3
or more candidates for nomination to or election to an elective office in the
same calendar year. MCL 169.208(3)
• Person: A business, individual, proprietorship, limited liability company,
firm, partnership, joint venture, syndicate, business trust, labor organization,
company, corporation, association, committee, or any other organization or
group of persons acting jointly. MCL 169.211(2)

13. The Michigan Department of State Bureau of Elections sends correspondence to any
Committee that files a Statement of Organization that identifies itself as an
Independent Committee. The boilerplate language of the correspondence indicates
that an Independent Committee may give the maximum contribution amounts per
election cycle after the criteria listed in MCL 169.208(3) is met.

14. The Michigan Campaign Finance Act governs responsibilities for committees, in
part, through a multitude of statutes:

• MCL 169.222 states that "A committee treasurer or other individual

designated on the statement of organization is 1·esponsible for the
committee's record keeping, report preparation, or report filing shall keep
detailed accounts, records, bills, and receipts as required to substantiate the
information contained in a statement or report filed pursuant to this act or
rules promulgated under this act.

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Although not defined explicitly in the Michigan Campaign Finance Act, Independent
Committees are referred to in campaign finance filings as PACs.
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 • MCL 169.233(10) states that "if a candidate, treasurer, or other individual
designated as responsible for a committee's record keeping, report
preparation, or report filing knowingly files an incomplete or inaccurate
statement or report required by this section, that individual is subject to a
civil fine of not more than $1,000.00."
• MCL 169.243 states that "an expenditure shall not be made, other than for
overhead or normal operating expenses, by an agent or an independent
contractor, including an advertising agency, on behalf of or for the benefit of a
person unless the expenditure is reported by the committee as if the
expenditure were made directly by the committee, or unless the agent or
independent contractor files a report of an independent expenditure as
provided in section 51. The agent or independent contractor shall make
known to the committee all information required to be reported by the
committee. A person who knowingly is in violation of this subsection is guilty
of a misdemeanor and shall be punished by a fine of not more than $1,000.00,
or imprisoned for not more than 90 days, or both, and if the person is other
than an individual the person shall be fined not more than $10,000.00.

15. The IRS.gov website provides in part numerous rules, guidelines, and regulations
pertaining to operation of 501(c)(4) non-profit social welfare organizations:

• To be tax-exempt as a social welfare organization described in Internal

Revenue Code (IRC) section 501(c)(4), an organization must not be organized
for profit and must be operated exclusively to promote social welfare. The
earnings of a section 501(c)(4) organization may not inure to the benefit of
any private shareholder or individual.
• To be operated exclusively to promote social welfare, an organization must
operate primarily to further the common good and general welfare of the
people of the community (such as by bringing about civic betterment and
social improvements).
• Seeking legislation germane to the organization's programs is a permissible
means of attaining social welfare purposes. Thus, a section 501(c)(4) social
welfare organization may further its exempt purposes through lobbying as its
primary activity without jeopardizing its exempt status.
• The promotion of social welfare does not include direct or indirect
participation or intervention in political campaigns on behalf of or in
opposition to any candidate for public office. However, a section 501(c)(4)
social welfare organization may engage in some political activities, so long as
that is not its primary activity.
• Every organization exempt from federal income tax under IRC section 501(a)
must file an annual information return, form 990, except in part: An exempt
organization (other than a private foundation) that normally has annual
gross receipts of $50,000 or less and therefore is ineligible to file an annual
election Form 990-N instead of an annual information return.

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16.Peninsula Fund (PF) is a 50l(c)(4) that was incorporated in and around July 2017
by a law firm. Affiant states that records and interviews indicate after the
Peninsula Fund was created, it was used as a tool to predominantly fund activities
related to Lee Chatfielcl's political office. A Peninsula Fund Board of Directors'
Consent Resolution elated June 30, 2017, lists Anne Minard as president, Becky
Boyce as vice-president, Jill Larder as secretary/treasurer, and Renae Moore as
assistant secretary/treasurer. The Peninsula Fund articles of incorporation state
that the president shall be the principal executive officer of the corporation and be
subject to the control of the board of directors, shall in general supervise and control
all the business and affairs of the corporation. On February 1, 2019, a board of
directors' consent resolution was approved authorizing execution of a contract for
services between the Peninsula Fund and Victor Strategies for Victor Strategies to
serve as consultant.

17.At the time of the Peninsula Fund incorporation, Renae Moore served as a
government solutions senior compliance specialist with the law firm that
incorporated the Peninsula Fund. She maintained this role throughout the
existence of the Peninsula Fund which dissolved in April 2021. Renae Moore was
interviewed and stated that the communication she relied upon for accurate record­
keeping and reconciliation for the Peninsula Fund came from Anne Minard. Renae
Moore stated that she often relied upon Anne to vet expenses charged to the
Peninsula Fund including determination on if expenses were legitimate or not.
Renae Moore stated over time, especially in 2020, Anne submitted fewer and fewer
receipts which made the reconciliation process extremely difficult.

18. Moore further stated that although Anne Minard submitted a resignation from the
Peninsula Fund board in March 2019, she maintained the same role in acting as
president from that time on while also being paid as a consultant. Throughout the
Peninsula Fund's existence, Anne had access to bank accounts, writing checks, and
otherwise coordinating and directing Peninsula Fund expenses. Board members
from the Peninsula Fund were interviewed and globally agreed they took no active
role in approving expenses, managing finances, or otherwise undertaking general
oversight. Of note, a policies and procedures document, drafted by the law firm that
incorporated the Peninsula Fund, from November 2018 notes in part that "PF
expenditures must stay within the scope of the purposes of the entity ... expenses
that fall outside the scope of the entity's purpose include dry cleaning, haircuts,
personal clothing, satellite radio services, fitness memberships, and other personal
expenditures that do not further the purposes of the Fund." Additionally, the
document states that "all expense reimbursements and credit card reimbursements
must be submitted on Fund forms and submitted with receipts for approval to the
President of the Fund."

19.Form 990 tax records for the Peninsula Fund show that in the years 2018, 2019,
and 2020 it listed its business address as P.O. Box 1013, East Lansing, MI 48826.
This is the same address used by Victor Strategies on its invoices in 2020.

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20.Lift Up Michigan is a 501(c)(4) incorporated in and around September 2015 by
Robert Minard. From its incorporation through 2023, Lift Up Michigan was
operated by Robert and Anne Minard. This included maintaining control of Lift Up
Michigan banking activities, contributions, and expenditures. Records show that
over the course of 2019 and 2020 approximately $107,500 was donated from the
Peninsula Fund into Lift Up Michigan. Anne Minard directed these donations.

21. The following is a list of Independent PA Cs formed and associated with Lee
Chatfield which all list Anne Minard as the Treasure of the Committee:

• Chatfield Majority Fund- formed in and around August 2015

• Chatfield Majority Fund II - formed in and around December 2017
• Chatfield Majority Fund III - formed in and around April 2019
• Chatfield Majority Fund IV - formed in and around February 2020

22. On August 25, 2015, Anne Minard, on behalf of Chatfield Majority Fund, filed form
8871, "Political Organization Notice of Section 527 Status" and claimed tax-exempt
status for the fund.

23.MCL 750.159i(l) prohibits conducting a criminal enterprise and provides that a

person employed by, or associated with, an enterprise shall not knowingly conduct
or participate in the affairs of the enterprise directly or indirectly through a pattern
of racketeering activity. Racketeering activity includes committing, attempting to
commit, conspiring to commit, or aiding and abetting, soliciting, coercing, or
intimidating a person to commit an offense for financial gain by obtaining money,
property, or any other thing of value. Eligible predicate offenses include, but are
not limited to, embezzlement under MCL 750.174 (regardless of whether the
principal is a non-profit organization), embezzlement by a public official under MCL
750.175, and larceny under MCL 750.356.

24.MCL 750.174 prohibits embezzlement and states in part that a person who as the
agent, servant, or employee of another person, governmental entity within this
state, or other legal entity or who as the trustee, bailee, or custodian of the property
of another person, governmental entity within this state, or other legal entity
fraudulently disposes of or converts to his or her own use, or takes or secretes with
the intent to convert to his or her own use without the consent of his or her
principal, any money or other personal property of his or her principal that has
come to that person's possession or that is under his or her charge or control by
virtue of his or her being an agent, servant, employee, trustee, bailee, or custodian,
is guilty of embezzlement. The statute prescribes additional punishment if the
victim is a nonprofit corporation or charitable organization. MCL 750.174(8) states
that except as otherwise provided in this subsection, the values of money or other
personal property embezzled in separate incidents pursuant to a scheme or course
of conduct within any 12-month period may be aggregated to determine the total
value of money or personal property embezzled. If the scheme or course of conduct is

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 directed against only 1-person, governmental entity within this state, or other legal
entity, no time limit applies to aggregation under this subsection.

25. MCL 750.356 prohibits larceny and states in relevant part that a person who steals
the money of another person is guilty of a crime punishable as provided in this
section.

26. MCL 750.157a prohibits conspiring to commit a crime and states in relevant part
that any person who conspires together with one or more persons to commit an
offense prohibited by law is punishable as provided in this section.

27.MCL 750.175 prohibits embezzlement by a public officer and states in relevant part
that any person holding any public office in this state, or the agent or servant of any
such person, who knowingly and unlawfully appropriates to his own use, or to the
use of any other person, the money or property received by him in his official
capacity or employment, of the value of 50 dollars or upwards, shall be guilty of a
felony, punishable as provided in this section.

28. MCL 400.293 prohibits various actions as to the money of charitable organizations.
In relevant part, the section prohibits knowingly diverting or misdirecting
contributions to a purpose or organization other than for which the funds were
contributed or solicited. "Charitable organization" means a benevolent, educational,
philanthropic, humane, patriotic, or eleemosynary organization of persons that
solicits or obtains contributions solicited from the public for charitable purposes.
The term includes a chapter, branch, area office, or similar affiliate or person
soliciting contributions within the state for a charitable organization that has its
principal place of business outside the state. MCL 400.272. Offenses are punishable
as provided in MCL 400.293.

29. During the investigation, it became clear that Lee Chatfield, Stephanie Chatfield,
Anne Minard, and Robert Minard there were converting and stealing non-profit,
candidate committee, and/or PAC money. The information supporting these findings
is as follows:

Count 1, Criminal Enterprises - Conducting

30. Being a person employed by or associated with an enterprise, to wit: The Michigan
House of Representatives and/or the Peninsula Fund and/or Chatfield Majority
Fund and/or Chatfield Majority Fund II and/or an organization, association, other
legal entity, or a group of persons associated in fact, did knowingly conduct or
participate in the affairs of the enterprise directly or indirectly through a pattern of
racketeering activity, consisting of two or more of the following incidents of
racketeering, which had the same or substantially similar purpose, or result, or
participant, or victim, or method of commission, and which amount to or pose a
threat of continued criminal activity; contrary to MCL 750.159i(l).

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 Predicate 1

31. On or about February 2020 through April 2021, in the City of East Lansing,
defendant LEE CHATFIELD did commit and/or aid or abet in the commission of the
following offense for financial gain, to wit: being an agent, servant, or employee of
the Peninsula Fund, a non-profit corporation or charitable organization, did convert
to his own use, money or other personal property of his principal, having a value of
$1,000 01· more but less than $20,000, that came into the defendant's possession or
under the defendant's charge or control by virtue of his relationship with the
principal; contrary to MCL 750.l74(5)(c).

32. The following facts support of Predicate 1: 2

From February 2020 through April 2021, Lee Chatfield made $132,000 in purchases
on his personal Chase credit card. Peninsula Fund money was used to pay off the entire
$132,000 balance. Numerous charges during this time frame are clearly personal in
nature. For example, in November 2020, Lee, Stephanie and their children went on
vacation to Universal Studios in Orlando, Florida. While on vacation with his family,
Lee's credit card was used to make purchases at the Spider-Man Shop (a Spider-Man
themed souvenir shop located in Universal Studios theme park), Three Broomsticks (a
Harry Potter themed restaurant in Universal Studios theme park); Honeydukes (a Harry
Potter themed candy store in Universal Studios theme park). Additional transactions
include grocery and restaurant purchases while on vacation, purchases at wineries, party
stores, and restaurants; food delivery purchases through Uber Eats; and reoccurring bills
through Apple.com. Transactions also include shopping purchases at Ugg, Coach, and a
surf shop in Florida. Transactions of a personal nature during this time frame total at
least $1,700.00. All charges during this time frame were paid using funds from the
Peninsula Fund, a social welfare organization.
Lee and Stephanie Chatfield worked together to facilitate using Peninsula Fund
money to pay for Lee's personal credit card charges. While Lee appeared to be the person
who generally used his personal Chase credit card, Stephanie's role was to monitor the
balance and make payments from the Peninsula Fund's accounts. For example, in
September of 2020 (less than 4 months before Chatfield would leave office) in a text
message exchange between Lee and Stephanie where they discussed the balance on Lee's
credit card, Stephanie stated, "I don't want to get caught come January with our tail
between our legs and no money in the account to pay it off." This is during a time frame
when every dollar charged to the Chase credit card is paid off with money from the
Peninsula Fund's accounts. In context, Stephanie is not referring to using their own
personal money or money from a permissible source to pay the balance on Lee's personal
credit card. Text messages where Stephanie indicates to Lee that she made a payment of
the Lee's personal credit card coincide with credit card payments made to Lee's personal
credit card directly from Peninsula Fund accounts.

2Affiant alleges the facts under Predicate 1 also support Counts 2 and 3 in Lee Chatfield's
complaint and Count 1 and 2 in Stephanie Chatfield's complaint.
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 Additionally, using Peninsula Fund money to pay a credit card balance associated
with personal purchases diverted Peninsula Fund money to a purpose other than that for
which the funds were contributed or solicitecl.3

Predicate 2

33. On or about November 2, 2020-December 10, 2020, in the City of East Lansing,
defendant LEE CHATFIELD did commit and/or aid or abet in the commission the
following offense for financial gain, to wit: being an agent, servant, or employee of
the Chatfield Majority Fund, a non-profit corporation or charitable organization, did
convert to his own use, money or other personal property of his principal, having a
value of $1,000 or more but less than $20,000, that came into the defendant's
possession or under the defendant's charge or control by virtue of his relationship
with the principal; contrary to MCL 750.l 74(5)(c) OR IN THE ALTERNATIVE did
commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund, the value of the property stolen was $1,000 or more but less than
$20,000; contrary to MCL 750.356(3)(a).

34. The following facts support Predicate 2: 4

Predicates 2-6 involve different checks with a common scheme. In general, Lee
Chatfield has Anne Minard write a check to either Aaron Chatfield, Paul Chatfield, or
Wilbur Lovitt from either the Chatfield Majority Fund or Chatfield Majority Fund 2. With
each check, either Lee Chatfield or Anne tells the recipient that that a portion of the
money is to be returned to Lee after the check is cashed. There are five checks associated
with this scheme: two written from the Chatfield Majority Fund and three written from
Chatfield Majority Fund 2. The Chatfield Majority Fund is a section 527 charitable
organization, so embezzlement counts and predicates associated with those checks are
embezzlements from a non-profit organization. Chatfield Majority Fund 2 is not a non­
profit organization. Each check is slightly different.
Predicate 2 involves a $5,000 check drawn on the Chatfield Majority Fund and
written by Anne Minard to Aaron Chatfield. The check is dated November 2, 2020. It is
not labeled as wages or a bonus. Additionally, the Chatfield Majority Fund does not have
employees. Aaron Chatfield informed investigators that Lee Chatfield gave the check to
him and said that Aaron could keep $1,500 and Lee would take $3,500 back. Rebekah
informed investigators that Anne gave her the check with instructions to give money back
to Lee. The check is deposited into Aaron and Rebekah's account a week later, on
November 9, 2020. On November 13, 2020, Rebekah withdraws $3,500 ($1,500 as a
cashier's check to Lee and $2,000 as cash for Lee). Lee cashed or deposited the check on
December 10, 2020. This all occurs leading up to Lee and Stephanie's family vacation to
Odando, Florida, and Universal Studios (Lee Chatfield Predicate 1 and Counts 1 and 2;
Stephanie Chatfield Counts 1 and 2) and contemporaneous with an extravagant trip that

3 While a violation ofMCL 400.293 is not a predicate for CCE, these facts support Count
13, Charitable Trust Act - Felony Violation.
4 Affiant alleges that the facts under Predicate 2 also support Count 4 in Lee Chatfield's

complaint.
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Lee Chatfield, Rob Minard, Aaron Chatfield, and Paul Chatfield took to Miami, Florida.
In context, the evidence supports that Lee directed Anne to write this check.
Additionally, though it does not form the basis of one of our counts, Wilbur Lovitt
received a check from the Chatfield Majority Fund 3 on November 2, 2020, the same clay
Aaron's November 2, 2020, check was written. Wilbur informed investigators that he
received the check before the trip to Miami, Florida with Lee, Robert, Aaron, Paul, but he
does not recall being told to do anything with the check. Wilbur was not working for the
Chatfield Majority Fund 3 at the time.

Predicate 3

35. On or about December 12, 2018, in the City of East Lansing, defendant LEE
CHATFIELD did commit and/or aid or abet in the commission of the following
offense for financial gain, to wit: being an agent, servant, or employee of the
Chatfield Majority Fund, a non-profit corporation or charitable organization, did
convert to his own use, money or other personal property of his principal, having a
value of$1,000 or more but less than $20,000, that came into the defendant's
possession or under the defendant's charge or control by virtue of his relationship
with the principal; contrary to MCL 750. l 74(5)(c) OR IN THE ALTERNATIVE did
commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund, the value of the property stolen was $1,000 or more but less than
$20,000; contrary to MCL 750.356(3)(a).

36. The following facts support Predicate 3: 5

Predicate 3 involves a $5,000 check drawn on the Chatfield Majority Fund and
written by Anne Minard to Wilbur Lovitt. The check is elated December 12, 2018, and is
labeled "wages" in the memo line. Wilbur informed investigators that he received the
check from Aaron or Paul while they were in the Bahamas together. Lee Chatfield, Robert
Minard, Aaron Chatfield, Paul Chatfield, Robert Anderson, and Wilbur Lovitt went to the
Bahamas together from December 14, 2018-December 17, 2018. The trip cost
approximately $32,000 and was paid for by Robert Minard. While in the Bahamas, Wilbur
used $2,000 of the money from the check himself and gave the remaining $3,000 back to
Lee. Some of the $3,000 was given back to Lee directly and some was given back to Lee
through Lee requesting that Wilbur cover various out-of-pocket expenses in the Bahamas.
Wilbur stated that at the time, he was told that it was a "bonus check" for wages for work
he had clone in the past, but Wilbur knew it wasn't just that, and that he would be giving
some of the money back to Lee. Wilbur believes some of this was explained to him by
Aaron. Aaron told investigators that he gave Wilbur a check with instructions that money
should go back to Lee. Aaron told investigators that Lee or Anne handed him the check to
give to Wilbur with instructions to give money back to Lee. In context, it appears that Lee
directed Anne to write this check.

5Affiant alleges the facts under Predicate 3 also support Count 5 in Lee Chatfielcl's
complaint.
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 Predicate 4

37. On or about November 27, 2018-December 11, 2018, in the City of East Lansing,
defendant LEE CHATFIELD did commit and/or aid or abet in the commission of the
following offense for financial gain, to wit: being an agent, servant, or employee of
the Chatfield Majority Fund 2, did convert to his own use, money or other personal
property of his principal, having a value of $1,000 or more but less than $20,000,
that came into the defendant's possession or under the defendant's charge or control
by virtue of his relationship with the principal; contrary to MCL 750.174(5)(c) OR
IN THE ALTERNATIVE did commit the offense oflarceny by stealing money that
belonged to the Chatfield Majority Fund 2, the value of the property stolen was
$1,000 or more but less than $20,000; contrary to MCL 750.356(3)(a).

38. The following facts support Predicate 4: 6

Predicate 4 involves a $1,645 check drawn from the Chatfield Majority Fund 2 and
written by Anne Minard to Aaron Chatfield. The check is dated November 27, 2018. The
check is part of a scheme to use PAC money to pay for personal retail and bar expenses
incurred by Lee and others while on a trip to Las Vegas, Nevada in May 2018. Lee
Chatfield and others improperly used Peninsula Fund money to pay for $1,645.00 in retail
and bar expenses in May of 2018. Anne Minard writes a check to Aaron for $1,675, the
amount of the improper expenses. Days later, Aaron deposits the check and withdraws
$1,645. $1,645 is deposited into Lee and Stephanie's account. On December 11, 2018,
Anne emails Renee Moore a series of deposits, including a check from Lee and Stephanie
to the Peninsula Fund for $1,645. Anne includes a note that says, "the one from Lee and
Stephanie is the reimbursement for the Vegas expense." Aaron told investigators that it
was either Anne or Lee who told him what to do with the check, but that if it was Anne, it
would be because Lee told her what to say.

Predicate 5

39.On or about November 30, 2018-December 7, 2018, in the City of East Lansing,
defendant LEE CHATFIELD did commit and/or aid or abet in the commission of the
following offense for financial gain, to wit: being an agent, servant, or employee of
the Chatfield Majority Fund 2, did convert to his own use, money or other personal
property of his principal, having a value of $1,000 or more but less than $20,000,
that came into the defendant's possession or under the defendant's charge or control
by virtue of his relationship with the principal; contrary to MCL 750.17 4(5)(c) OR
IN THE ALTERNATIVE did commit the offense oflarceny by stealing money that
belonged to the Chatfield Majority Fund 2, the value of the property stolen was
$1,000 or more but less than $20,000; contrary to MCL 750.356(3)(a).

G Affiant
alleges the facts under Predicate 4 also support Count 6 of Lee Chatfield's
complaint.
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 40. The following facts support Predicate 5: 7

Predicate 5 involves a $1,000 check drawn from the Chatfield Majority Fund 2 and
written to Aaron Chatfield by Anne Minard. The check is dated November 30, 2018 (three
days after the check in Predicate 4/Count 6 and shortly before the December 2018
Bahamas trip). As to this check, Aaron Chatfield told investigators that Lee said, "I'm
going to give you a check. You're going to give me a certain amount back. And then maybe
the rest if needed." Aaron said the same thing happened with Wilbur (appearing to refer
to Predicate 3/Count 4). In context, this check was not Aaron's wages, and its entire
amount is the amount embezzled or stolen.

Predicate 6

41. On or about November 2, 2020, in the City of East Lansing, defendant LEE
CHATFIELD did commit and/or aid or abet in the commission of the following
offense for financial gain, to wit: being an agent, servant, or employee of the
Chatfield Majority Fund 2, did convert to his own use, money or other personal
property of his principal, having a value of $1,000 or more but less than $20,000,
that came into the defendant's possession or under the defendant's charge or control
by virtue of his relationship with the principal; contrary to MCL 750.l74(5)(c) OR
IN THE ALTERNATIVE did commit the offense oflarceny by stealing money that
belonged to the Chatfield Majority Fund 2, the value of the property stolen was
$1,000 or more but less than $20,000; contrary to MCL 750.356(3)(a).

42. The following facts support Predicate 6: 8

Predicate 6 involves a $5,000 check drawn from the Chatfield Majority Fund 2,
written by Anne Minard to Paul Chatfield. The check is dated November 2, 2020, the
same day as Aaron's $5,000 check in Predicate 2/Count 4. Again, this all occurs leading up
to Lee and Stephanie's family vacation to Universal Studios in Orlando, Florida and
contemporaneously with Lee Chatfield, Paul Chatfield, Aaron Chatfield, Bob Anderson,
and Wilbur Lovitt's November 2020 trip to Miami, Florida. Paul told investigators that he
remembers receiving a $5,000 check and Lee requested "maybe $1,000" back. Paul could
not remember if this occurred before the 2018 Bahamas trip, or in 2020 before the Miami
trip. Paul told investigators that if they (Lee and Anne) asked for money back, Paul
assumed that it would be used to cover the cost of the trips. In context, this check appears
designed to provide both Paul and Lee with spending money for their trips and does not
appear to be associated with wages.

7 Affiant alleges the facts under Predicate 5 also support Count 7 in Lee Chatfield's
complaint.
8 The facts alleged under Predicate 6 also support Count 8 in Lee Chatfield's complaint.

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 Predicate 7

43. On or about January 29, 2019-March 1, 2019, in the City of Lansing, defendant
LEE CHATFIELD did commit and/or aid or abet in the commission of the following
offense for financial gain, to wit: did, being a person holding public office in this
state, knowingly and unlawfully appropriate to his/her own use or to the use of any
other person, money or property received by him in his official capacity or
employment, to wit; money in the form of mileage reimbursement, of the value of
$50.00 or more; contrary to MCL 750.175.

44. The following facts support Predicate 7: 9

As a member of the Michigan House of Representatives, Chatfield was entitled to

receive a travel reimbursement each week for one round trip between Lansing, Michigan
and his home district, Michigan's 107 th district. One round trip from Lansing, Michigan to
Chatfield's home district is 448 miles. He was also entitled to receive travel
reimbursements for any miles driven within his district for official legislative business.
Each month, Chatfield submitted paperwork showing which days he claimed to have
traveled to/from district and how many in-district miles were traveled, if any. The round
trip and in-district gas and travel reimbursements pay $0.58 per mile in 2019 and $0.575
in 2020.
During his time as the Michigan Speaker of the House, Lee Chatfield sought travel
reimbursements from the State of Michigan through the State Officers Compensation
Commission. From January 2019 through December 2020, Lee Chatfield received over
$30,000 in reimbursement for gas and travel expenses. Per Michigan House of
Representative Guidelines and Policies, "Reimbursement at the State Standardized
mileage rate for one round trip per week between the legislature's home district and the
state capitol shall continue as a separate expense reimbursement. The trip must be made
to qualify for reimbursement." However, Chatfield's calendar indicates that many of the
times he sought travel reimbursements, a trip from Lansing to his home district was not
made. Of the 42,337 miles Chatfield sought reimbursement for, approximately 21,280
miles appear to be associated with trips not actually taken. This amounts to
approximately $12,299.84 that was improperly reimbursed.
One improper reimbursement is associated with a trip Lee Chatfield claimed he
took on January 29, 2019. Calendar entries and financial transactions reflect that Lee
Chatfield was in Ann Arbor, Michigan on January 29, 2019, and that he flew from the
Detroit (DTW) airport to Phoenix, Arizona on January 30, 2019. On March 1, 2019, Lee
Chatfield signed a reimbursement form that claimed he made a trip from Lansing to
Levering and back on January 29, 2019. It does not appear that this trip occurred. By
falsely claiming that it did and seeking reimbursement, Lee Chatfield embezzled public
funds in the amount of $259.84.

9 The facts alleged under Predicate 7 also support Count 9 in Lee Chatfield's complaint.
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 Predicate 8

45. On or about February 26, 2019-March 1, 2019, in the City of Lansing, defendant
LEE CHATFIELD did commit and/or aid or abet in the commission of the following
offense for financial gain, to wit: did, being a person holding public office in this
state, knowingly and unlawfully appropriate to his/her own use or to the use of any
other person, money or property received by him in his official capacity or
employment, to wit; money in the form of mileage reimbursement, of the value of
$50.00 or more; contrary to MCL 750.175.

46. The following facts support Predicate 8: 10

Paragraph 47 is incorporated by reference. Another improper reimbursement is

associated with a trip Lee Chatfield claimed he took on February 26, 2019. Calendar
entries, financial transactions, and other records reflect that Lee Chatfield was in Puerto
Rico from February 23, 2019, to February 25, 2019, and flew from Puerto Rico to the
Detroit (DTW) airport on February 26, 2019. Additionally, records reflect that Lee
Chatfield had meetings in Lansing on February 26, 2019, and stayed overnight in Detroit
on February 26, 2019. On March 1, 2019, Lee Chatfield signed a reimbursement form that
claimed he made a trip from Lansing to Levering and back on February 26, 2019. This
trip did not occur. By falsely claiming that it did, and seeking reimbursement, Lee
Chatfield embezzled public funds in the amount of $259.84.

Predicate 9

47. On or about September 2, 2019-October 2, 2019, in the City of Lansing, defendant

LEE CHATFIELD did commit and/or aid or abet in the commission of the following
offense for financial gain, to wit: did, being a person holding public office in this
state, knowingly and unlawfully appropriate to his/her own use or to the use of any
other person, money or property received by him in his official capacity or
employment, to wit; money in the form of mileage reimbursement, of the value of
$50.00 or more; contrary to MCL 750.175.

48. The following facts support Predicate 9: 11

Paragraph 47 is incorporated by reference. Another improper reimbursement is

associated with a trip Lee Chatfield claimed that he took on September 2, 2019. Calendar
entries, financial transactions, and other records reflect that Lee Chatfield on September
2, 2019, did not drive to his home district, but instead flew there, landing at the Pellston,
Michigan airport in the afternoon on September 2, 2019. Lee Chatfield signed a
reimbursement form that claimed he made a trip from Lansing to Levering and back on
October 2, 2019. This trip did not occur. By falsely claiming that it did, and seeking
reimbursement, Lee Chatfield embezzled public funds in the amount of $259.84. While
only three instances of improper reimbursement were selected to form the basis of

10 The facts alleged under Predicate 8 also support Count 10 in Lee Chatfield's complaint.
11 The facts alleged under Predicate 9 also support Count 11 in Lee Chatfield's complaint.
14
predicate offenses and criminal charges, there are numerous trips that fit this general
pattern, and it appears that Lee Chatfield embezzled approximately $12,299.84 through
this scheme.

Predicate 10

49. On or about December 2017 through December 2019, in the City of Lansing,
defendant LEE CHATFIELD did commit and/or aid or abet in the commission of the
following offense for financial gain, to wit: being an agent, servant, or employee of
the Peninsula Fund, a non-profit corporation or charitable organization, did convert
to his own use, money or other personal property of his principal, having a value of
$1,000 or more but less than $20,000, that came into the defendant's possession or
under the defendant's charge or control by virtue of his relationship with the
principal; contrary to MCL 750.17 4(5)(c).

50. The following facts support Predicate 10: 12

From December 2017-December 2019 Lee Chatfield rented an apartment from

Walnut Tree Properties, a company that was owned by the Michigan Automobile Dealers
Association, a lobbying firm that is run by Terry Burns. Lee Chatfield's lease was from
February 2015-January 2016 and appears to have converted to a month-to-month
arrangement thereafter. From December 2017-December 2019, Lee Chatfield's monthly
rent was $775.00 and was paid for by the Peninsula Fund. Lee Chatfield subleased one of
the bedrooms in the apartment to Gerald Sullivan for $250.00 per month. Sullivan paid
Lee Chatfield directly via check, and Lee Chatfield did not reimburse Peninsula Fund for
the profit he made by subleasing a portion of the apartment. While it remains
questionable whether financing Lee Chatfield's Lansing apartment is genuinely related to
Peninsula Fund's social welfare purpose, providing Lee Chatfield with a subleasing
income stream is not related to the fund's purpose. Lee Chatfield embezzled $6,225.00
from the Peninsula Fund by failing to reimburse the fund for the money that they spent on
the apartment.

Additional Counts

51. The facts alleged in Paragraphs 1-50 are herein incorporated by reference. Based
on these facts, Affiant requests charging Lee Chatfield with the additional following
counts:

Count 2, Embezzlement from a non-profit organization $1,000-$20,000

On or about February 2020 through April 2021, in the City of East Lansing, defendant
LEE CHATFIELD did commit the following offense, to wit: being an agent, servant, or
employee of the Peninsula Fund, a non-profit corporation or charitable organization, did
convert to his own use, money or other personal property of his principal, having a value of

12 The facts alleged under Predicate 10 also support Count 12 in Lee Chatfield's complaint.
15
$1,000 or more but less than $20,000, that came into the defendant's possession or under
the defendant's charge or control by virtue of his relationship with the principal; contrary
to MCL 750.l74(5)(c).

Count 3, Conspiracy to comn1it embezzlement from a

non-profit organization $1,000-$20,000

On or about February 2020 through April 2021, in the City of East Lansing, defendant
LEE CHATFIELD did unlawfully conspire, combine, confederate, and agree together with
STEPHANIE CHATFIELD and/or other known or unknown persons to commit the
following listed offense; contrary to MCL 750.157a: Embezzlement from a non-profit
organization $1,000-$20,000, MCL 750.174(5)(c).

Count 4, Embezzlement from a non-profit $1,000-$20,000

or in the alternative larceny $1,000-$20,000

On or about November 2, 2020-December 10, 2020, in the City of East Lansing, defendant
LEE CHATFIELD did commit the following offense, to wit: being an agent, servant, or
employee of the Chatfield Majority Fund, a non-profit corporation or charitable
organization, did convert to his own use, money or other personal property of his principal,
having a value of $1,000 or more but less than $20,000, that came into the defendant's
possession or under the defendant's charge or control by virtue of his relationship with the
principal; contrary to MCL 750.17 4(5)(c)

OR IN THE ALTERNATIVE

did commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund, the value of the property stolen was $1,000 or more but less than $20,000;
contrary to MCL 750.356(3)(a).

Count 5, Embezzlement frmn a non-profit $1,000-$20,000

or in the alternative larceny $1,000-$20,000

On or about December 12, 2018, in the City of East Lansing, defendant LEE CHATFIELD
did commit the following offense, to wit: being an agent, servant, or employee of the
Chatfield Majority Fund, a non-profit corporation or charitable organization, did convert
to his own use, money or other personal property of his principal, having a value of $1,000
or more but less than $20,000, that came into the defendant's possession or under the
defendant's charge or control by virtue of his relationship with the principal; contrary to
MCL 750.l 74(5)(c)

OR IN THE ALTERNATIVE

did commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund, the value of the property stolen was $1,000 or more but less than $20,000;
contrary to MCL 750.356(3)(a).

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 Count 6, Embezzlement from a non-profit $1,000-$20,000
or in the alternative larceny $1,000-$20,000

On or about November 27, 2018-December 11, 2018, in the City of East Lansing,
defendant LEE CHATFIELD did commit the following offense, to wit: being an agent,
servant, or employee of the Chatfield Majority Fund 2, did convert to his own use, money
or other personal property of his principal, having a value of $1,000 or more but less than
$20,000, that came into the defendant's possession or under the defendant's charge or
control by virtue of his relationship with the principal; contrary to MCL 750.l74(5)(c)

OR IN THE ALTERNATIVE

did commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund 2, the value of the property stolen was $1,000 or more but less than
$20,000; contrary to MCL 750.356(3)(a).

Count 7, Embezzlement from a non-profit $1,000-$20,000

or in the alternative larceny $1,000-$20,000

On or about November 30, 2018-December 7, 2018, in the City of East Lansing, defendant
LEE CHATFIELD did commit the following offense, to wit: being an agent, servant, or
employee of the Chatfield Majority Fund 2, did convert to his own use, money or other
personal property of his principal, having a value of $1,000 or more but less than $20,000,
that came into the defendant's possession or under the defendant's charge or control by
virtue of his relationship with the principal; contrary to MCL 750.17 4(5)(c)

OR IN THE ALTERNATIVE

did commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund 2, the value of the property stolen was $1,000 or more but less than
$20,000; contrary to MCL750.356(3)(a).

Count 8, Embezzlement from a non-profit $1,000-$20,000

or in the alternative larceny $1,000-$20,000

On or about November 2, 2020, in the City of East Lansing, defendant LEE CHATFIELD
did commit the following offense, to wit: being an agent, servant, or employee of the
Chatfield Majority Fund 2, did convert to his own use, money or other personal property of
his principal, having a value of $1,000 or more but less than $20,000, that came into the
defendant's possession or under the defendant's charge or control by virtue of his
relationship with the principal; contrary to MCL 750.17 4(5)(c)

OR IN THE ALTERNATIVE

17
did commit the offense of larceny by stealing money that belonged to the Chatfield
Majority Fund 2, the value of the property stolen was $1,000 or more but less than
$20,000; contrary to MCL 750.356(3)(a).

Count 9, Embezzlement by Public Officer over $50

On or about January 29, 2019-March 1, 2019, in the City of Lansing, defendant LEE
CHATFIELD did commit the following offense, to-wit: did, being a person holding public
office in this state, knowingly and unlawfully appropriate to his/her own use or to the use
of any other person, money or property received by him in his official capacity or
employment, to wit; money in the form of mileage reimbursement, of the value of $50.00 or
more; contrary to MCL 750.175.

Count 10, Embezzlement by Public Officer over $50

On or about February 26, 2019-March 1, 2019, in the City of Lansing, defendant LEE
CHATFIELD did commit the following offense, to-wit: did, being a person holding public
office in this state, knowingly and unlawfully appropriate to his/her own use or to the use
of any other person, money or property received by him in his official capacity or
employment, to wit; money in the form of mileage reimbursement, of the value of $50.00 or
more; contrary to MCL 750.175.

Count 11, Embezzlement by Public Officer over $50

On or about September 2, 2019-October 2, 2019, in the City of Lansing, defendant LEE

CHATFIELD did commit the following offense, to-wit: did, being a person holding public
office in this state, knowingly and unlawfully appropriate to his/her own use or to the use
of any other person, money or property received by him in his official capacity or
employment, to wit; money in the form of mileage reimbursement, of the value of $50.00 or
more; contrary to MCL 750.175.

Count 12, Embezzlement from a non-profit organization $1,000-$20,000

On or about December 2017 through December 2019, in the City of Lansing, defendant
LEE CHATFIELD did commit the following offense, to wit: being an agent, servant, or
employee of the Peninsula Fund, a non-profit corporation or charitable organization, did
convert to his ownuse, money or other personal property of his principal, having a value of
$1,000 or more but less than $20,000, that came into the defendant's possession or under
the defendant's charge or control by virtue of his relationship with the principal; contrary
to MCL 750. l 74(5)(c).

Count 13, Charitable Trust Act-Felony Violation

On or about February 2020 through April 2021, in the City of East Lansing, defendant
LEE CHATFIELD did commit the following offense, to wit: did knowingly divert or
misdirect contributions to a purpose or organization other than for which the funds were

18
contributed or solicited, and the aggregate amount of money solicited exceeded $1,000.00;
contrary to MCL 400.293.

WHEREFORE, the facts and circumstances developed during this investigation

demonstrate probable cause to believe that Lee Chatfield committed criminal offenses
under Michigan Law.

04/15/2024
Affiant Date

Subscribed and Sworn before me on: 4/ I I,,, / 2-<-f

1
Date

Honorab~~ 'P'736'if3
Judge,54Bistrict Court,
East Lansing, Michigan

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